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Política de Privacidade

Índice

  1. INFORMAÇÕES IMPORTANTES E QUEM SOMOS
  2. INFORMAÇÕES SOBRE O NOSSO REPRESENTANTE NA UNIÃO EUROPEIA E OS NOSSOS DADOS
    DE CONTACTO
  3. QUE DADOS PESSOAIS RECOLHEMOS?
  4. DE QUE FORMA USAMOS OS SEUS DADOS PESSOAIS?
  5. FINALIDADES DE UTILIZAÇÃO DOS SEUS DADOS PESSOAIS
  6. DIVULGAÇÃO DOS SEUS DADOS PESSOAIS
  7. TRANSFERÊNCIA DE DADOS FORA DO ESPAÇO ECONÓMICO EUROPEU
  8. SEGURANÇA DOS DADOS
  9. RETENÇÃO DAS SUAS INFORMAÇÕES
  10. OS SEUS DIREITOS
  11. ALTERAÇÕES A ESTA POLÍTICA DE PRIVACIDADE

Data de vigência: 1 de fevereiro de 2020

INFORMAÇÕES IMPORTANTES E QUEM SOMOS

O Paybyrd.com, o qual inclui a Paybyrd B.V. e empresas afiliadas (doravante, “paybyrd.com”, “nós”, “o nosso” ou “a nossa”) respeita a privacidade do Utilizador e está empenhado em proteger os dados pessoais do mesmo. A presente Política de Privacidade apresenta ao Utilizador a forma como efetuamos o tratamento dos seus dados pessoais quando utiliza as nossas plataformas e os nossos serviços (referidos coletivamente como “Serviços”) e quando utiliza o nosso site. A Política não se aplica a sites, produtos ou serviços de terceiros.

A Paybyrd B.V. controla e é responsável por este site.

Durante o tratamento de dados pessoais de titulares dos dados localizados na União Europeia (UE) ou relacionados com a Paybyrd B.V., esta agirá enquanto responsável pelo tratamento dos dados ou subcontratante de dados. Quando a Paybyrd B.V. determinar a finalidade e a forma de tratamento dos dados pessoais do Utilizador, a Paybyrd B.V. é considerada responsável pelo tratamento dos dados, respetivamente. Aplicamos uma abordagem semelhante à proteção dos dados do Utilizador, quer estejamos a agir enquanto subcontratante de dados ou responsável pelo tratamento dos dados.

A presente Política de Privacidade é emitida em nome do Paybyrd.com e, como tal, quando usamos os termos “Paybyrd.com”, “nós”, “o nosso” ou “a nossa” na presente Política de Privacidade, referimo-nos à empresa relevante no Grupo Paybyrd.com que for responsável pelo tratamento dos dados do Utilizador.

O Paybyrd.com está empenhado em proteger de forma adequada os dados pessoais do Utilizador, independentemente de onde são tratados e da localização do Utilizador. O Paybyrd.com está empenhado em fornecer proteção adequada aos dados pessoais do Utilizador quando estes são transferidos fora do EEE.

INFORMAÇÕES SOBRE O NOSSO REPRESENTANTE NA UNIÃO EUROPEIA E OS NOSSOS DADOS DE CONTACTO

  • A Paybyrd B.V. está registada nos Países Baixos com o número comercial 76168573, tendo sede social em Keizersgracht 391A, 1016 EJ, Amsterdão, Países Baixos. A Paybyrd está registada na Visa enquanto ISO (organização de vendas independente) e atua em nome dos seus comerciantes com os seus parceiros contratantes.
  • O Paybyrd.com designou um encarregado da proteção de dados (EPD) para supervisionar as questões relacionadas com a presente Política de Privacidade e todas as operações do Paybyrd.com abrangidas pelas leis de proteção de dados europeia. Se o Utilizador tiver alguma questão relativa à presente Política de Privacidade, incluindo pedidos para exercer os seus direitos legais, deverá entrar em contacto com o EPD através dos dados abaixo indicados. O EPD do Paybyrd.com pode ser contactado em inglês, francês ou espanhol.

    E-mail: dpo@paybyrd.com

    Morada:
    Data Protection Officer paybyrd b.v.
    Keizersgracht 391A, 1016 EJ,
    Amsterdam
    The Netherlands

O Utilizador tem o direito de apresentar uma queixa a qualquer momento aos organismos governamentais relevantes, contudo, deverá ponderar contactar a Paybyrd em primeira instância, para que possamos abordar as suas preocupações diretamente.

WHAT PERSONAL DATA DO WE COLLECT?

Personal data, or personal information, means any information about an individual from which that person
can be identified. It does not include data from which the identity of the individual cannot be
discerned (anonymous data).

We use different methods to collect data from and about you. Data is collected through the following:

Our Website

When you use our website, we may collect, use, store and transfer the following data:

  • Information you give us while using our website. We may ask you to provide us with personally
    identifiable information while you use our website. This includes your full name, e-mail address,
    phone number and your website.
  • Automated technologies or interactions. We may use cookies, server logs and other technologies, such
    as web beacons, to collect information that your browser sends us when you are using our website.
    This includes your computer’s internet protocol, browser type, browser version, the country from
    which you visited our website, how you arrived at our website, length of your visit and which pages
    you viewed. Please refer to our cookie policy for
    further information about how we use cookies and similar
    technologies.

Our Services

When you use our Services, we may collect, use, store and transfer the following personal data:

  • Information you give us. We may collect personal data directly from you, as set out below:
    • Personal data collected from Sandbox users. We will ask you to provide us with personal data when
      you register to use our Sandbox Hub (see “Get Sandbox” button on our website). If you register to our
      Sandbox Hub, we will collect, store and process personal data, such as your full name, e-mail address and
      your website.
    • Personal data collected from our merchants. We will ask you to provide us with personal data when you
      apply to become our merchant. We may require you to provide us with additional personal data as you use our
      Services. If you are a merchant applying to use our Services, we will collect, store and process personal data
      relating to you and other individuals associated with you, such as full name, email address, date of birth,
      home address, proof of address, photocopy of a personal identification card or passport and other information
      as required to on-board you and meet applicable legal requirements.
  • Information provided by third parties. We may collect personal data about you from third parties, as set out below:
    • Personal data collected while processing your payment. If you are a card-holder making a payment
      to a merchant using our Services to process your payment, we may, directly or through a merchant
      using our payment processing service, collect, store and process financial and transaction related
      personal data about you and your transaction. This may include your billing address, delivery
      address, date of birth, purchase amount, date of purchase, payment method, credit or debit card
      number, bank account information and additional necessary information required to process your
      transaction.
    • When required for compliance with applicable laws (including specifically anti-money laundering
      and counter-terrorism financing laws and regulations), we may verify your information and collect
      information from publicly available sources, credit reference or fraud prevention agencies or check
      data against government sanction lists, either directly, or using identity verification providers or
      due diligence and screening information providers.
    • When securing our website and Services, we may collect details about your device, your
      transaction, your computer’s internet protocol and other technical information, through our data
      security and firewall providers.
    • When marketing our Services, we may collect identity and contact data from publicly available
      sources.

Our Sandbox HUB

Our Sandbox Hub is intended to be used as a test environment, and we do not envisage collecting, storing
or processing any personal data while you use our Sandbox Hub. Please do not use any personally
identifiable information, including cardholder data, when using the Sandbox Hub, other than when
entering your login details. Our Sandbox environment is different and distinct to our live Hub
environment and is not designed to store or process cardholder data.

HOW DO WE USE YOUR PERSONAL DATA?

We will process your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you as
    our merchant.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests
    and fundamental rights do not override those interests, such as mitigating financial loss or other
    harm to our merchants, you and us.
  • Where we need to comply with legal or regulatory obligations, such as detecting and preventing
    fraud.
  • Where we need to improve and analyse our products, website, systems and tools.

Examples of how we may process your personal data include:

  • To manage risk and protect the website, the Services and you from fraud, abuse and other
    illegitimate activities, by monitoring, detecting and preventing such activities.
  • To comply with our obligations and to enforce the terms of our website and Services, including to
    comply with all applicable laws and regulations.
  • Process a payment, communicate with third-parties regarding a payment, and provide related
    customer service.
  • Monitor illegitimate activities and prevent information security risks related to our website and
    Services.
  • Evaluate your application to use our Services and verify your identity for compliance purposes.
  • Respond to inquiries, send service notices and provide customer support.
  • For audits, regulatory purposes, and compliance with industry standards.
  • Notify you about changes to the nature or terms of our Service.
  • To administer our website, including troubleshooting, data analysis, testing, research,
    statistical and survey purposes.
  • To improve our website to ensure that content is presented in the most effective manner.
  • Authenticate your access to your account.
  • To improve or modify our Services.
  • To develop new products.
  • To send marketing communications.
  • To conduct aggregate analysis and develop business intelligence that enable us to operate,
    protect, make informed decisions, and report on the performance of our business.
  • For our legitimate interests, including to:
    • enforce the terms of our website and Services;
    • manage our everyday business needs, such as monitoring and analysing; and
    • anonymise personal data in order to provide aggregated statistical data to third parties,
      for example to our clients.

NOTICE TO OUR MERCHANTS

We may collect, use and disclose certain personal data about your customers when acting as your service
provider. You are responsible for making sure that your customer’s privacy rights are respected,
including ensuring appropriate disclosures about third party data collection and use. You must comply
with the personal data protection laws of your country of origin and of those countries in which you
offer products or services and, in particular when processing and sending personal data to us in the
context of using the Services and submitting transactions. If you entered into our Merchant Services
Agreement, you are also responsible for compliance with the requirements set out in our Merchant
Services Agreement and for the notification of your customers of the Mastercard Binding Corporate Rules
(as amended from time to time and currently (available here), including your customers’ right to enforce
these rules as third-party beneficiaries.
To the extent that we are acting as your data processor, we will process personal data in accordance
with the terms of our agreement with you and your lawful instructions.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out a description of the purposes we plan to use your personal data and the lawful basis for
our processing activities below:

Purpose Activity Type of data Legal basis for processing including basis of legitimate interest
To use data analytics to improve our website, products/services, marketing, customer
relationships and experiences
Technical, device and usage details Necessary for our legitimate interests (to define types of customers for our products and
services, to keep our website updated and relevant, to develop our business and to inform
our marketing strategy)
To administer and protect our business and this website (including troubleshooting, data
analysis, testing, system maintenance, support, reporting and hosting of data)
Identity, contacts and technical details
  • Necessary for our legitimate interests (for running our business, provision of
    administration and IT services, network security, to prevent fraud and in the
    context of a business reorganisation or group restructuring exercise)
  • Necessary to comply with a legal obligation

DISCLOSURES OF YOUR PERSONAL DATA

We share your personal data with trusted third parties for the purpose of providing our Services and
promoting our business, as follows:

Affiliates. Your information may be shared with our affiliates within the Paybyrd.com Group, to provide
you with our Services. The relevant Paybyrd.com entity is the party responsible for overall management
and use of your personal data, with Paybyrd B.V. being that party with respect to services provided
respectively by Paybyrd B.V. that concern data subjects in the EU.

Business partners, payment industry suppliers and participants to your transactions. We may share your
personal data with our merchants and their service providers, card schemes, payment method providers and
third party acquirers, as necessary to process payments or provide our Services. The information shared
includes:

  • Personal data necessary to facilitate the transaction and activities related to your transaction;
  • Personal data to help our partners resolve disputes and detect and prevent fraud; and
  • Personal data and performance analytics to help our merchants better understand the uses of their
    platform and to help our merchants enhance their customers’ experiences.

Third-party service providers. We may also use third-party service providers acting on our behalf. These
service providers help us with data and cloud services, website hosting, data analysis, application
services, advertising networks, information technology and related infrastructure, customer service,
communications and auditing.

Advertising and remarketing networks. Our website uses remarketing and conversion tracking technologies
provided by Google AdWords (for further details about the Remarketing product we use, (see here) for the
product’s privacy policy, (see here) and Facebook Pixel (for further details about the Facebook product
we use, (see here) for details about the information we may share with this provider, (see here). This
technology allows us to display targeted advertising to users who have already visited our website when
they use the websites of the partner networks of Google and Facebook across the internet. We may add
similar providers to those mentioned here in the future. Third-party vendors, including Google and
Facebook, use cookies to serve you ads based your visits to our website. Please refer to our cookie policy for
further information about how these technologies are used on our website.

Other third parties. We will share your personal data with third parties in the event of any
reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any
portion of our business, assets or stock.

Safety, Legal Purposes and Law Enforcement. We may share your personal data with third parties to detect,
prevent or otherwise address fraud, security or technical issues, or to protect against harm to the
rights, property or safety of Paybyrd.com, our users, customers, employees or the public or as otherwise
required by law. We also use and disclose your personal data as we believe necessary (i) under
applicable law, or payment method rules; (ii) to enforce our terms and conditions, or our Merchant
Service Agreement and other agreements, as applicable; (iii) to protect our rights, privacy safety or
property, and/or that of our affiliates, you or others; and (iv) to respond to requests from courts, law
enforcement agencies, regulatory agencies, and other public and government authorities, which may
include authorities outside your country of residence.

All our third-party service providers and other entities in the group are required to process the data in
accordance with applicable data protection regulations and to take appropriate security measures to
protect your personal information in line with EU data protection standards and our policies.
We do not allow our third-party service providers to use your personal data for their own purposes.

In addition, when a third-party entity processes your personal data on our behalf and according to our
instructions, we sign a written agreement with it that specifically describes its obligations with
regard to security and data protection, in accordance with European data protection laws. We only permit
them to process your personal data for specified purposes.

TRANSFER OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

When possible, the data we collect from you is stored and processed at data centres in the EEA.

Paybyrd.com will take all reasonable legal, technical, and organisational measures to ensure that if your
data is transferred outside of the EEA, it will be treated securely and with an adequate level of
protection compared to the level of protection offered within the EEA.

We may share your personal data with members of the Paybyrd.com Group who are based outside of the EEA.
We may share your personal data with partners, suppliers or sub-processors based in countries outside of
the EEA.

We have taken specific steps, in accordance with European data protection law, to protect your personal
data. In particular, we will strive to restrict the transfer of your personal data to countries that
have been deemed to provide an adequate level of protection for personal data by the European
Commission.

Transfers of personal data outside of the European will take place only where the organisation receiving
the personal data has provided us with adequate safeguards, and subject to a written agreement, in line
with the requirements of European data protection law applicable to processors and data transfers.

If you transact with parties outside the EEA, for example by: (i) transacting with a merchant based
outside the EEA; (ii) using a payment method based or commonly used outside of the EEA; or (iii) using a
non-EEA currency; we may be required to transfer your personal data to those parties in order to provide
the Services you requested.

DATA SECURITY

Protecting your information and your privacy is extremely important to us. Being entrusted with some of
your most valuable data, we have set high standards for data security. We have put in place appropriate
security measures to prevent your personal data from being accidentally lost, used or accessed, altered
or disclosed in an unauthorised manner.

We are PCI DSS (Payment Card Industry Data Security Standard) Level 1 compliant, which is the highest
standard set by the payment card industry to ensure that credit card data is processed, stored or
transmitted in a secure environment.

In addition, we limit access to your personal information to those employees and third parties who have a
business need to know. They will only process your personal information on our instructions and they are
subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach and will notify you and
any applicable regulator of a suspected breach where we are legally required to do so.

RETENTION OF YOUR INFORMATION

We retain your personal data in an identifiable format for the least amount of time necessary to fulfil
our legal or regulatory obligations and for our business purposes. We may retain your personal data for
longer periods than required by law if it is in our legitimate business interests and not prohibited by
law.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it
for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To
determine the appropriate retention period for personal data, we consider the amount, nature, and
sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes for which we process your personal data and whether we can achieve those
purposes through other means, and the applicable legal requirements.

Data are retained for the following periods of time:

Type of data Purpose pursued Period of retention
Identity and contact details of merchants Performing a contract, providing services and notifying changes to our terms or privacy
policy Review of new merchants
5 years after termination of the contract, or from the last contact, as applicable
Technical, device and usage details (data analytics) Improving our website, products/services, marketing, customer relationships and experiences Prospects: Three (3) years from the data collection or from the last contact of the
prospect. Clients: Five (5) years after termination of the Agreement Data collected through cookies: see our cookie policy
Identity, contacts and technical details Administering and protecting our business and this website Clients: Five (5) years after termination of the Agreement Data collected through cookies:
see our cookie policy
Buyer’s credit card and transaction information Processing a transaction
Performing a contract
Complying with anti-money laundering and regulatory requirements
Five (5) years from date of transaction or the end of the business relationship

If your account is closed, we reserve our right to retain and access your personal data for so long as
required to comply with applicable laws. We will continue to use and disclose your personal data in
accordance with this privacy policy.

The cookies we use have defined expiration times; unless you visit our website within that time, the
cookies are automatically disabled and retained data is deleted. Please consult our cookie policy for more
information.
In some circumstances you can ask us to delete your data: see below for further information about your
rights.
In some circumstances we may anonymise your personal data for statistical purposes in which case we may
use this information indefinitely without further notice to you.

It is important that the personal data we hold about you is accurate and current. Please keep us informed
if your personal data changes during your relationship with us.

YOUR RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal
data:

  • Request access to your personal data (commonly known as a “data subject access request”). This
    enables you to receive a copy of the personal data we hold about you and to check that we are
    lawfully processing it.
  • Request correction of the personal data we hold about you. This enables you to have any incomplete
    or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new
    data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data
    where there is no good reason for us continuing to process it. You also have the right to ask us to
    delete or remove your personal data where you have successfully exercised your right to object to
    processing, where we may have processed your information unlawfully or where we are required to
    erase your personal data to comply with local law. Note, however, that we may not always be able to
    comply with your request of erasure for specific legal reasons which will be notified to you, if
    applicable, at the time of your request.
  • Object to processing for your personal data where we are relying on a legitimate interest (or those
    of a third party) and you object to the processing of your personal data on this ground as you feel
    it impacts on your fundamental rights and freedoms. You also have the right to object where we are
    processing your personal data for direct marketing purposes. In some cases, we may demonstrate that
    we have compelling legitimate grounds to process your information which overrides your rights and
    freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the
    processing of your personal data in the following scenarios: (a) if you want us to establish the
    data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c)
    where you need us to hold the data even if we no longer require it as you need it to establish,
    exercise or defend legal claims; or (d) you have objected to our use of your data but we need to
    verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a
    third party you have chosen, your personal data in a structured, commonly used, machine- readable
    format. Note that this right only applies to information which you initially provided consent for us
    to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However,
    this will not affect the lawfulness of any processing carried out before you withdraw your consent.
    If you withdraw your consent, we may not be able to provide certain products or services to you.
  • Request for manual review. We may use automated decision making in processing your personal
    information while processing your transaction. If we made an automated decision about your
    transaction, you have the right to contest the decision, to express your point of view and to
    require a manual review of the decision.

If you wish to exercise any of the rights set out above, please contact dpo@paybyrd.com or use the postal
address mentioned at the beginning of this privacy policy. Once we have received notification that you
have withdrawn your consent, we will no longer process your information for the purpose or purposes you
originally agreed to, unless we have another legitimate basis for doing so in law.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to update this privacy policy at any time, and we will publish an updated privacy
policy if we do so. We may also notify you in other ways from time to time about the processing of your
personal information.

Privacy Policy